Donald Grey, an inspector with the Occupational Safety and Health Consultants agency (OSHCON), says preparation is the key to avoiding OSHA penalties. OSHCON is a state agency, jointly funded by the State of Texas and OSHA.

“We help companies prepare for OSHA inspections,” he said. “We tell them what areas are in compliance and what areas need to be corrected, hopefully before OSHA gets there.”

As with the OSHA consultation service, OSHCON typically works with smaller companies.

“We have worked with grain facility inspections,” Grey said. Granaries are covered under OSHA regulation 29GFR 1910 with 1910.272 specific to grain. Many of the hazards he’s seen mirror the ones McGee mentioned but his list is longer.

Missing equipment guards on machinery is a common hazard, he said. “Also, fans must be guarded and openings can be no more than two inches. OSHA can cite that.” They can also cite broken or bent handles on shovels, brooms, rakes and other tools. Files or other tools without handles are also unacceptable. Ladders with damaged rungs, broken steps, or lacking slip-proof treads may be cited as can damaged supports—bent, loose or cracked. Ladders may be repaired, he said, “but not in the field. They must be taken back to the shop and restored to manufacturer’s quality.”

He said exit lights that are not working or failure to post an exit sign are hazards. Blocked exits or exit signs on overhead doors are also not allowed.

Grey said electrical problems are often identified in grain handling and storage facilities. Something as simple as a bent ground plug can be cited. A missing ground pin or a pin broken off in an outlet may be hazards.

Using an adaptor to cause equipment to be ungrounded is not allowed. Ungrounded equipment may be cited.

Grey says a $10 to $15 electrical testing kit “is a good investment and is easy to use. I recommend getting one to test for open ground. And then get a qualified electrician to make repairs.”

He said hand tools—drills, etc.—without ground are hazards. Other electrical hazards include frayed wires; no or insufficient insulation on wires; wires not spliced correctly; loose insulation, outlets, cords or equipment placed in wet areas; use of cords not suitable for a specific use or location; flexible cords run through windows or doors or used as permanent wiring; spliced extension cords; and uninspected cords and plugs.

Circuit breaker panels without doors, or without adequate working room—at least 30 inches in front—are cited hazards. “Jewelry worn during electrical work also may be cited,” Grey says.

“A lot of this stuff is just common sense. People don’t like to mess with electricity. It can be scary.” That’s why using that common sense is vital, he said.

A few bonehead actions also occur with welding equipment. Grey said oxygen and acetylene tanks should be stored a minimum of 25 feet from each other “unless they are behind a wall with at least 30 minutes of fire protection. Compressed gas cylinders must be secure. We also see damaged hoses on cylinders and the wrong clamps on cylinders. Also, if an adjacent person is not protected during welding activity (not wearing eye protection, for instance) the company may be cited.”

He said training is a key to many safety requirements. “No training on electrical safety,” he said, can be cited by OSHA.

Things as simple as failing to maintain a restroom properly may be considered safety hazards. Grey said citations may be made for having no paper towels or other means to dry hands in a restroom.  Having no toilet paper, soap or hot or tepid water is also an offense.

“The paperwork can be the killer,” Grey said. Repairs and corrections must be documented. “If they are not documented, they never happened,” he said. OSHA must see annual inspection documents, training procedures, emergency protocols and evidence that hazards have been corrected.

“At OSHCON, we focus on high hazard industries,” Grey said. Criteria mirrors that of OSHA consultation—250 employees of fewer—and voluntary employer participation. “We have just 20 days to get initial reports and paperwork done,” he said.

Although 90 percent of OSHCON’s funding comes from OSHA, they do not report voluntary inspection findings to OSHA for enforcement.

 

 

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